Home > Bulletin Archive > Reg Z TIL Changes July 22, 2009 (Revised August 26, 2009) Reg Z TIL Changes and Appraisal Delivery Requirements In 2008, Federal regulations were passed that would passed would amend the Truth in Lending Act (TIL) implemented through Regulation Z. The intent is to help prevent deceptive lending practices and to improve consumer information. There are two major impacts of the new regulations: 1. The implementation of waiting periods between disclosure delivery and closing 2. Re-disclosure throughout the processing of the loan each time the APR increases by .125% The new regulations take effect for all applications taken on or after 7/30/09. To comply with this act, effective with applications received into underwriting 7/30/09 or after, 1AM will issue disclosures on all loans when received in underwriting. All regulatory waiting periods will apply in connection with these re-disclosures. Key Points: ◊ The regulation disallows the collecting of fees prior to the borrower receiving the disclosure and a subsequent waiting period. In order to insure compliance, 1AM will not accept files that reflect the collection of any up front fees by the broker. ◊ TIL disclosure are required for all owner occupied and second homes. ◊ There will be a waiting period of 7 business days after the mailing of the disclosures by 1AM to the borrower before the loan can close. ◊ There will be waiting a waiting period of 7 business days after the mailing of the latest re-disclosure before the loan can close; or a waiting period of 4 business days after e-mail or hand delivery of re-disclosures as evidenced by signed and dated documents from the borrower(s). ◊ An increase of more than .125% in the Annual Percentage Rate (APR) from the initial TIL requires the disclosure to be revised and reissued to the borrower. The borrower must receive a revised TIL disclosure at least 3 business days before closing. APPRAISAL DELIVERY: Appraisals must be received by the borrower a minimum of 3 business days prior to closing. If appraisals are being mailed, a 7 business day waiting period applies, in order to allow for mail time. Included are three examples to help illustrate the regulatory wait periods. These are provided only for the purposes of illustrating the new disclosure and waiting period requirements. Click Here for the Examples This information is for use by mortgage professionals only and should not be distributed to or used by consumers or other third parties. Information is accurate as of the date of printing and is subject to change without notice. PDF of this Bulletin